[ONLINE] Relief from Double Taxation – 12 November

This session concerns methods for the relief of double taxation in Maltese law. Specifically, the session shall delve into the following aspects of the subject:

• Economic double taxation (EDT) relief:
  • Rationale & types of EDT relief;
  • EDT relief mechanisms in the ITA;
    • The full imputation system (article 31, 59 and 60 of the ITA);
    • The participation exemption (as relevant for the relief of EDT); and
    • The indirect foreign tax credit.
  • Juridical double taxation relief:
    • Rationale & types of JDT relief;
      • Outbound considerations:
        • Ordinary direct foreign tax credit system;
        • Treaty relief
        • Unilateral relief
        • Commonwealth relief;
        • Flat-rate foreign tax credit.
        • The participation exemption (as relevant for the relief of JDT).
      • Inbound considerations:
        • Source rules;
        • Treaty relief as applicable to Malta as the ‘other Contracting State’.
      • Miscellaneous issues:
        • Switch-over clauses;
        • Anti-hybrid rules;
        • Subject-to-tax rules.

Instructed by: Dr Christopher Bergendahl. in: Uncategorized

Seminar Description

Seminar Description

This session concerns methods for the relief of double taxation in Maltese law. Specifically, the session shall delve into the following aspects of the subject:

• Economic double taxation (EDT) relief:
  • Rationale & types of EDT relief;
  • EDT relief mechanisms in the ITA;
    • The full imputation system (article 31, 59 and 60 of the ITA);
    • The participation exemption (as relevant for the relief of EDT); and
    • The indirect foreign tax credit.
  • Juridical double taxation relief:
    • Rationale & types of JDT relief;
      • Outbound considerations:
        • Ordinary direct foreign tax credit system;
        • Treaty relief
        • Unilateral relief
        • Commonwealth relief;
        • Flat-rate foreign tax credit.
        • The participation exemption (as relevant for the relief of JDT).
      • Inbound considerations:
        • Source rules;
        • Treaty relief as applicable to Malta as the ‘other Contracting State’.
      • Miscellaneous issues:
        • Switch-over clauses;
        • Anti-hybrid rules;
        • Subject-to-tax rules.

CPE

Qualifies for 3 CPE Core hours under the core competency area.

Seminar Fee

The seminar fee is Non Member €70.00, Members €60.00. The fee covers seminar participation and access to event resources.

A receipt will be issued to all participants.

Event Resources

Participants will receive the event resources by email.

Additional Information

For more information, kindly use the following communication mediums:

T: 21 58 53 74   M: 77 01 17 19   E: info@skillsmalta.com      Webpage: www.skillsmalta.com